This case arises from a single, momentary sideswipe on Interstate 95 in which the rightfront tire of the U-Haul truck driven by Corey Hayes-Goode contacted the left-rear corner of Rigoberto Lagunas-Antunez’s GMC van.
U-Haul filed certain motions challenging the testimony of Plaintiffs’ experts, Ruston Hunt, Daniel Wolfe, Steven Kean and Brooks Rugemer.
The Court dismissed Plaintiffs’ claims against U-Haul that were brought under a design defect theory (the “design defect claims”), but denied the motion as to Plaintiffs’ claims against U-Haul under a failure-to-warn theory, as well as to the Estate of Rigoberto’s wrongful death claim against U-Haul. All of Plaintiffs’ claims against Defendant Hayes-Goode remained.
Human Factors Expert Witness
Ruston M. Hunt holds a B.S. and M.S. in Industrial Engineering and a Ph.D. in Mechanical Engineering from the University of Illinois, where he also taught and conducted applied research on human error and electro-mechanical systems. With over 40 years of experience in human factors engineering, he has led extensive research and development projects for major government
agencies and Fortune 500 companies, focusing on operator support systems and human-system interfaces. Hunt has served as a faculty member and administrator at leading institutions, where he taught and developed programs in human factors and systems engineering.
Accident Reconstruction Expert Witnesses
Daniel M. Wolfe has a Bachelor of Science Degree in Engineering and a Doctor of Philosophy degree in Electrical and Electrical and Computer Engineering.
He is a member of the Society of Automotive Engineers, the National Association of Accident Reconstruction Experts, and the Optical Society of America. He is certified by the Society of Automotive Engineers to access and interpret Heavy Vehicle Event Data Recorders in commercial vehicles and is certified as a BOSCH Crash Data Retrieval technician.
Steven T. Kean has over 25 years of experience in traffic crash investigation and reconstruction, including more than 1,000 crash investigations. He has served as an Accident Reconstruction Team member since 2001 and as Team Leader since 2008, and he holds full accreditation as a Traffic Accident Reconstructionist from ACTAR.
Kean’s extensive specialized training—spanning advanced crash reconstruction, event data recorder analysis, heavy vehicle investigations, and human factors—demonstrates his comprehensive expertise in evaluating vehicle dynamics and driver behavior. He has been qualified and testified as an expert in multiple state courts, taught advanced crash reconstruction courses to law enforcement and legal professionals, and is an active member of leading professional organizations, including the National Association of Professional Accident Reconstruction Specialists and the Society of Automotive Engineers.
Trucking Expert Witness
Brooks Rugemer has over 30 years of experience in trucking safety, driver training, risk management, and accident investigation, including 12 years as a tractor-trailer operator with 1.4 million accident-free miles. He has hired and trained over 5,000 CDL drivers and is intimately familiar with FMCSRs, OSHA regulations, and accepted transportation safety practices.
Discussion by the Court
A. Motion to Exclude Expert Ruston Hunt
U-Haul provided that Hunt opined as to the location of the van relative to the Subject Truck at the time of the accident, that the Subject Truck was defective and unreasonably dangerous due to lacking certain technologies, and that U-Haul allegedly failed to provide adequate warnings and training to inexperienced renters.
On review of Hunt’s voluminous report, these opinions primarily involve (1) the Subject Truck being unreasonably dangerous and defective because “insufficient warnings and instructions were provided to renters” and because “it lacked a blind spot detection and warning system,” (2) the dangers of failing to “explicitly train” renters on the proper adjustment of the Subject Truck’s side view mirrors; and (3) the accident-prevention effect that blind-spot detection technologies “likely” would have had in this case, had they been installed on the Subject Truck.
Because Plaintiffs’ design defect claims are no longer viable, Hunt’s opinions that the Subject Truck was defective and unreasonably dangerous due to an alleged design defect are not relevant.
B. Motion to Exclude Expert Daniel Wolfe
Wolfe testified as to the Subject Truck’s alleged design defects and alternative technologies that allegedly could have prevented the instant accident.
As the proposed design-engineering expert, Wolfe’s testimony is relevant only with regard to the now-dismissed design defect claims. Therefore, pursuant to Federal Rule of Evidence 401, the Court granted U-Haul’s motion to exclude the testimony of expert Wolfe.
C. Motion to Exclude Expert Steven Kean
U-Haul took issue with two specific opinions proffered by Kean in his deposition: Plaintiffs’ van was in the Subject Truck’s blind spot prior to the accident, and the van was traveling faster than the Subject Truck at impact.
According to Plaintiffs, Kean’s testimony will “offer critical insight that will help the jury understand the sequence of events and the physical evidence underlying this collision.”
Because the Court can foresee the potential relevance of an accident reconstructionist’s testimony to Plaintiffs’ remaining claims, the Court denied without prejudice U-Haul’s motion to exclude the testimony of expert Steven Kean at this juncture, subject to a Daubert hearing at the appropriate time in the proceedings to ascertain the reliability of his proffered testimony.
D. Motion to Exclude Expert Brooks Rugemer
U-Haul provided that Rugemer’s testimony concerned the countermeasures that U-Haul should have taken in order to prevent the instant accident, such as giving additional training and safety information to inexperienced drivers of rental trucks.
According to Plaintiffs, Rugemer will “explain to the jury how commercial transportation companies manage blind spot and mirror adjustment risks, what reasonable industry practices exist to mitigate foreseeable lane-change collisions, and how U-Haul’s rental procedures fell short of those well-established standards.”
Because the Court can foresee the potential relevance of a commercial safety expert’s testimony to Plaintiffs’ remaining claims, the Court denied without prejudice U-Haul’s motion to exclude the testimony of expert Brooks Rugemer at this juncture, subject to a Daubert hearing at the appropriate time in the proceedings to ascertain the reliability of his proffered testimony.
Held
- The Court granted U-Haul’s motions to exclude the testimony of Ruston Hunt and Daniel Wolfe.
- The Court denied without prejudice U-Haul’s motions to exclude the testimony of Steven Kean and Brooks Rugemer.
Key Takeaway
Evidence is relevant if it has any tendency to make a fact more or less probable than it would be without the evidence, and the fact is of consequence in determining the action.
Case Details:
| Case Caption: | Lagunas-Antunez V. Hayes-Goode |
| Docket Number: | 2:24cv416 |
| Court Name: | United States District Court, Virginia Eastern |
| Order Date: | February 26, 2026 |
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